Amended Particulars of Claim

The Plaintiff is a writer, counsellor and an experz on the Church of
Scientology. The Plaintiff lives in East Grinstead and is the owner of a
house known as Avalon, Cranston Road, East Grinstead, West Sussex RH19
3HQ.

The First and Second Defendants have as their objects the propagation of
the principles and beliefs of the system of Scientology, a system of beliefs
devised by L. Ron Hubbard. The First Defendant (or "the Church of
Scientology") is incorporated in Australia and registered in the United
Kingdom; the Second Defendant is an English corporation.

The Third Defendant is the Executive Director of the Second Defendant;
the Fourth Defendant is the Secretary to the Board of trustees of the First
Defendant and is the Commanding Officer of the Church's Office of Special
Affairs; the Fifth, Sixth and Seventh Defendants are memebers and/or
employees of the First Defendant.

In or about June 1993 members of the Chruch of Scientology who were
employees and/or agents of the First and Second Defendants widely
distributed and thereby published to households in the East Grinstead area
by means of posting by hand a leaflet entitled "The Cause of Conflicts
and Violence". The dirstribution of the leaflets was authorised and/or
permitted by the First to Fourth Defendants.

The said leaflet contained the following words of and concerning the
Plaintiff:
"THE CAUSE OF CONFLICT AND VIOLENCE"

In the inside pages, a photograph of the Plaintiff was captioned,
"Deprogrammer Jon Atack", and next to the following words:

"DISCRIMINATION FOR PROFIT"

"Although it may seem a foreign concept to some, it has actually become
a big business in some parts of the world to attack religious communities. A
few individuals, most having no personal convictions of their own, use lies
and distortions to stir up conflicts between people of different beliefs.
Having created division and upset, they then offer their 'services' (for a
considerable fee) to anyone who wants to change the religous convictions of
another ...

"'Deprogramming' often requires forcible kidnapping and
imprisonment as a first step in the process of 'persuasion' ..."

Anti-religious actions carried out for money
"Deprogrammers usually say they do what they do out of some honest
concern for the familiy. This is far from the truth ..."

"Atack could never succeed in Scientology due to its high ethical
requirements and has had nothing to do with the Church for ten years.
Despite all of this, he still inaccurately describes himself as an 'expert'
on Scientology ..."

"Another area of conflict which Mr. Atack has attempted to stir up
is in the field of drug rehabilitation ... And to handle the hard-core
addicts, the Church strongly supports the Narconon programme which utilizes
Mr. Hubbard_s drug rehabilitation technology to not only get addicts off
drugs but to keep them off for good ... So why would Jon Atack attack a
programme which ist working towards a drug-free society? It is the Church's
experience that such people often have hidden ulterior motives which they
use to justify their actions. Perhaps that is the case, perhaps not. Mr.
Atack should be asked to declare waht vested interest he has in drug use
continuing in society".

The said words were false.

PARTICULARS OF FALSITY
(1) The Plaintiff dos not use lies and distortions deliberately to stir up
conflicts between people of different belifs in order to create a market
for his 'expensive and unethical' services.
(2) The Plaintiff does not use kidnapping and imprisonment or any other
criminal or unlawful means in order to coerce people to change their
religious beliefs, or for any other purpose.
(3) The Plaintiff does not falsely and hypocritically state that he carried
out his work solely out of concern for families, when in fact he does it
solely for money.
(4) The Plaintiff does not falsely and dishonestly represent himself to be
an expert on Scientology.
(5) The Plaintiff does not have any vested financial or any other hidden
ulterior interest in drug use continuing in society.

On or about 2nd April 1994 the Fourth defendant on behalf of herself
and the First Defendant wrote and sent to the Editor of The Sunday Times,
Mr. Andrew Neill, a letter containing the following words concerning the
Plaintiff:

"Perhaps the first thing to make clear is that his sources, Jon Atack,
a convicted drug dealer, and Gary Scarff, a self-confessed perjurer, are
engaged in a scam to manipulate the media. They seemed to have found an easy
mark in Richard Palmer. The scheme is simple they find gullible reporters
and give them sensational lies which make good copy. The reporter gets an
easy story. In return, they demand that the Church pays over tens of
thousands of pounds, for what? So they will no longer seek out such
reporters, and there will be no more 'embarrassing stories' " Palmer,
like a foll, fell for it hook, line and sinker.

Jon Atack has a criminal conviction and is known to fratrnize with
criminals. One of his close friends went to prison for stealing from the
Church another was arrested and jailed for lewdeness. Yet another was
convicted for jewel theft. A vicar-fried was exposed in the national press
for conducting orgies at his vicarage. Yet Palmer treated him as a reliable
source ..

Jon Atack earns what living he makes in two ways: He is paid by the press
for his sensational allegations, and he charges families seventy pounds an
hour to kidnap members of religious groups to break their faith.

His victims are the ones who should rightly adopt Atacks cry: "I am
astonished that the police cannot protect a British subject from such an
undesirable as Atack," for they are the people who have really
suffered.

Perhaps if Atack got a job and earned an honest living he would not continue
to be an menace to those around him. Unfortunately, Palmer fell under
Atack's spell, he decided to write the sensational stroy that Atack dictated
and damned the facts.

Scientology has been expanding all over the wold for over 4 decades. The
ramblings of Atack and Scarff no more tell the stroy of Scientology than the
propaganda of Goebbels told the stroy of Judaism. The place to find the
truth about Scientology is to read a Scientology book, or visit one of our
Chruches and make up ones own mind. Millions have done so, and have found
the answers they have been looking for. This is why Scientology continues to
grow. Two embittered scam artists do not speak for all those who have been
gotten off drugs, improved their family lives and relationships, and become
happier and more capable through Scientology.

The Plaintiff will ask the Court to infer that the First and Fourth
Defendants intended that the said letter, or the effect thereof, be
published in The Sunday Times, thereby maximising the damage to the
Plaintiff.

The words set out in Paragraph 7 were false.

PARTICULARS OF FALSITY
(1) The Plaintiff is not a convicted drug dealer.
(2) The Plaintiff is not engaged in a scam to maipulate the media and
extort money from the Church of Scientology, which scam involved telling
sensational lies to gullible reporters about Scientology and then
demanding tens of thousands of pounds from the Church of Scientology
in return for stopping telling such lies.
(3) The Plaintiff has no close friends who was convicted of stealing from
the Church or for "lewdness" or for jewel theft. Nor does he
have any close friend who was a vicar and was exposed in the national
press for conducting orgies at his vicarage.
(4) The Plaintiff does not kidnap members of religious groups.
(5) The Plaintiff is not a menace to those around him.
(6) The Plaintiff does not spread lies and propaganda out of bigotry and
hatred.

The words set out in Paragraphs 5 and 7 were published maliciously.

(1) The Plaintiff repeats Pragraphs 1 and 2 herein.
(2) The Church of Scientology was founded by L. Ron Hubbard. It was first
incorporated in 1953 and now claims a following of millions around the
world. The "Hubbard Communications Office" ("HCO")
regularly issues bulletins and policy letters which direct how
Scientologists are to operate. These are written in a jargon which is
virtually unitelligible to non-Scientologists and for which several
dictionaries have been produced. The Church also incorporates the
"Sea Organisation", a paramilitary organisation in which
members wear pseudo-naval uniform and hold pseudo-naval ranks.
(3) The Church of Scientology demands absolute conformity with its ideas
and teaching from members and thereby prevents them from thinking for
themselves.
(4) The Church of Scientology has displayed continual hostility to any
criticism and imposes harsh internal rules which isolate its members
from the outside world and prevent them from forming an independet view
of the merits of Scientology.
(5) Scientologists are discouraged from reading anything hostile to
Scientology ("entheta") and ordered not to communicate
with anyone critical of its teachings. Scientologists are forbidden
to chriticise the precepts of Hubbard and Scientology. Even attempting
to discuss auditing techniques is known as "verbal tech" and
is forbidden. Offenders ar subjected to a "Committee of
Evidence" a Scientology tribunal.
(6) Harsh punishments, including corporal punishments, withholding of
food and the levying of fines, are meted out to members who transgress
rules and criticise the organisation. If a member publicly speaks out
against Scientology or leaves the organisation, he or she is declared a
"Suppressive Person" and deemed to be an enemy of the
organisation; no member of the Church (not even members of the
Suppressive Person's family) may have any contact with him or her.
A Scientologist in contact with or related to someone who is declared
a suppressive prson is dubbed a "Potential Trouble Source"
and will be ordered to "disconnect" (i.e., sever all
communication with) that person. Members have been ordered to
disconnect from spouses, close family, friends and business partners.
(7) Scientology publications are clearly intended to incite hatred of
those critical of its ideas and techniques. The Church of Scientology
has a policy of retaliating to investigations and criticisms of its
organisation and practices by making personal attacks on the characters
of the critics. The aim of the policy ist to deter further
investigation and criticism by intimidating and frightening any critics
or potential critics of the organisation. In support of this contention
the Plaintiff relies, among other things, on policy documents issued
by the Church of Scientology, including, but not limited to, the
following:
(a) A document entitled "HCO Policy Letter of 25 February 1966 --
Attacks of Scientology" issued from the Hubbard Communications
Office at the United Kingdom headquarters of the Church of
Scientology at Saint Hill, which document includes the following
instructions to members of the organisation:
"NEVER agree to an investigation of Scientology.
ONLY agree to an ivestigation of the attackers."
"This is the correct procedure:
(1) Spot who is attacking us.
(2) Start investigating them promptly for FELONIES or worse using
our own professionals, not outside agencies.
(3) Double curve our reply saying we welcome an investigation of
them.
(4) Start feeding lurid blood sex crime actual evidence to the
press.
"Don't ever submit tamely to an investigation of us. Make
it rough, rough on attackers all the way".
(b) A document entitled, "HCO Bulletin of 5th November 1967
--Critics of Scientology", which contained the following
instruction to members of Scientology:
"Our business is helping people to lead better lives. We
even help those who have committed crimes, for we are not here to
punish. But those who try to make life hard for us are at once at
risk."
"And we have this technical fact--those who oppose us have
crimes to hide. It's perhaps merely lucky that this is true. But it
is true. And we handle opposition well only when wi use it."
The Plaintiff relies on the full content of these documents.
(8) From aabout 1967 the Church operated the policy of "Fair Game"
which meant that any Suppressive Person could be "deprived of
property or injured by any means by any Scientologist without any
discipline of the Scientologist" and could be "tricked, sued,
lied to or destroyed". The said quotations come from a document,
the whole of which the Plaintiff relies on, entitled "HCO Policy
Letter of 18th Ocotober 1967 -- Penalties for Lower Conditions",
written by L. Ron Hubbard.
(9) After the "fair game" doctrine came under the scrutiny of the
public and the courts in the United States during the 1970s the Church
of Scientology claimed in 1980 that it abrogated the policy. The
Plaintiff contends that notwithstanding the official abrogation of the
policy the vengeful spirit and ethos of "fair game" survived
within the organisation.
(10) The Plaintiff was a member of the Church of Scientology from December
1974 until his resignation in October 1983. The Plaintiff left the
organisation because he disagreed with certain church practises.
(11) After leaving the organisation, the Plaintiff began zu counsel people
who were or had been members and wanted help to overcome psychological
problems caused by their assocation with the Church of Scientology. The
Plaintiff also undertook research into the life and writings of L. Ron
Hubbard. The Plaintiff's researches resulted in a book, "A Piece
of Blue Sky", which was published in the United States, Canada,
Australia, Holland and England in 1990. In 1992 the Plaintiff published
in England another book on Scientology entitled "The Total Freedom
Trap". The Plaintiff also acts regularly as an expert witness
giving evidence about the Chruch of Scientology, its techniques and
practises.
(12) As a consequence of the Plaintiff leaving the Church and of his
counselling and reasearch work, the Plaintiff was labelled a
"Suppressive Person" by the ruling body of the Chruch, the
Sea Organisation, on 31 March 1984. The Plaintiff will rely on the
terms of the written document declaring the Plaintiff's status as a
"Suppressive Person" as evidence of the Defendants' hostility
towards the Plaintiff.
(13) From 1983, the Church, in linde with its policy towards dissenters and
critics set out in (2) to (8) above, has conducted a malicious campaign
of harrasment to intimidate the Plaintiff and prevent him from
continuing his work in the area of Scientology. The Plaintiff will
reply on the following facts and matters in support of his contention.
(14) On various occasions between 1983 to date, members of the Church of
Scientology have visited the Plaintiff's home, kept watch on his
property, visitors and movements. The Plaintiff relies on the
following:
(a) At the end of 1983, a member of the Church whom the Plaintiff
recognised as Michael Rogers, also known as Michael McFarland,
kept the Plaintiff's hime in East Grinstead under surveillance.
(b) During 1985, Plaintiff's house was watched by his neighbour,
Jeremy Stevens, who is a member of the Church of Scientology.
(c) In the summer of 1991, two Scientologists whom the Plaintiff
recognised as Stephen Lake and Dale Bulbrook came to the
Plaintiff's door and told him that if he set foot in the
United STates again he would be served with court proceedings.
(d) Again in the summer of 1991, two Scientologists whom the
Plaintiff cannot identify persuaded the Planintiff's neighbour,
by falsely claiming that they were the Plaintiff's friends, to
let them into the Plaintiff's house. The Plaintiff was in fact at
home asleep and the Scientologists accused him of lying to the
press.
(e) In October 1991, the Plaintiff was accosted outside his home by
Cathy Sproule, an officer of the First Defendant at its East
Grinstead branch, and 2 video cameramen, who obstructed the
Plaintiff's movement. Miss Sproule was verbally abusive to the
Plaintiff.
(f) Towards the end of 1992, members of the Church of Scientology began
to appear in pairs at the Plaintiff's house about once a week. On
16 December 1992, one Vince Nash and another woman who did not give
her name appeared at the Plaintiff's house and stated that the
Plaintiffwas persecuting his religion and that he told lies. On 22
December 1992, Scientologists John Bradley and John Nash arrived at
11.15 p.m. at the Plaintiff's house, and was asked to leave by the
Plaintiff. On 12. January 1993, Scientologists John King and Jenny
Gray arrived at the Plaintiff's house and repeatedly called him a
failure. In January 1993, Scientologist Graham Zimmatore arrived at
the Plaintiff's house and entered uninvited through the front door.
He made abusive remarks to the Plaintiff and had to be pushed out
through the door.
(15) On 13 March 1994, the Fifth and Sixth Defendants and one other
Scientologist whom the Plaintiff cannot identify on behalf of
themselves and the First Defendant and/or authorised by the First
Defendant staged a public demonstration outside the Plaintiff's house,
displaying placards bearing the follwoing flase and damaging
allegations against the Plaintiff:
"Support your own family instead of destroying ours";
"Stop destroying families"; and "Get job like the
rest of us". At about 5.20 p.m. the police arrived and told the
the demonstrators to move on.
(16) On 15 March 1994, the Sixth Defendnt and other Scientologists whom
the Plaintiff cannot identify, on their own behalf and on behalf
of the First Defendant and/or authorised by the First Defendant,
staged another demonstration outside the Plaintiff's house this time
holding placards bearing the allegations: "Do not harm persons of
goodwill", "Respect the religious beliefs of others" and
"We oppose faith breaking".
(17) On 16, 17, 18 and 19 March 1994 the Sixth Defendant and other
Scientologists on their own behalf and on behalf of the First Defandant
and/or authorised by the First Defendant, again appeared with placards
outside the Plaintiff's house. The demonstration lasted between 10 and
40 minutes each day. On 19 March 1994 police confiscated the placards,
assured the Plaintiff and warned that if the demonstrators returned
they would be arrested.
(18) Despite the warning received from the police, on 6 April 1994, the
Sixth Defandant, and on 10 April 1994, the Fifth and Sixth Defendant
demonstrated outside the Plaintiff's house. Both demonstrations lasted
about 10 minutes.
(19) The Plaintiff will ask the Court to infer that these demonstrations
were held in order to cause the Plaintiff and his family nuisance
and inconvenience, fear, embarrassment and distress and also to
discredit him in the eyes of the local community by means of publicly
making false and damaging accusations against him; and were part of the
Church of Scientology's malicious campaign to deter the Plaintiff from
his work.
(20) Since 1983 the Plaintiff has on frequent occasions received telephone
calls from people who immediately hang up upon the Plaintiff answering.
It is to be inferred that this the calls are another intimidatory
tactic used and/or authorised by the Church of Scientology in their
campaign against the Plaintiff.
(21) Further, as part of the malicious campaign referred to in (5) above,
employees and/or agents of the Church of Scientology made false reports
of the criminal behaviour on the part of the Plaintiff to the Police
and Social Services. The Plaintiff relies on the following:
(a) In November 1992, Scientologist Austin Leniston on behalf of the
the Defendants, made a written report to the police which contained
the following allegations: "We unfortunately, have some
experience already with such abductions, both successful and
unsuccessful ... From the data we have collected, the key figure
at the back of this is a person named Jon Atack who specialises
in trying to damage Scientology with this kind of crime, as part
of a bigger criminal activity which is called 'Enforced
Deprogramming' ..." The Plaintiff will rely on the whole of
the said report.
(aa) On 15 November 1994 the Church of Scientology held a public
meeting at the Whitehill Centre, Whitehill Road, Crowborough. The
spokesman for the Chruch of Scientology was Kenneth Eckersley.
Shortly after the meeting, Kenneth Eckersley said to the Reverend
Michael John Ovey that the Plaintiff had raped someone and tried
to murder someone else, and that he was continually taking drugs.
Kenneth Eckersley made the said scurrilous and false accusations
against the Plaintiff authorised by and/or on behalf of the Church
of Scientology.
(b) In or about July 1993, Scientologist Charles Poulter on behalf of
the First Defendant and/or authorised by the First Defendant,
alleged that there were grounds to suspect the Plaintiff of
molesting his 4 year old daughter. As a result of the allegation,
the Plaintiff was visited at his home by a policewoman and a
social worker. Subsequently the Plaintiff received a letter from
Social Services confirming that they would not be taking any
further action and a letter of apology froum Charles Poulter. At
the time, the First Defendants knew the allegation to be
completely groundless, but nonetheless cynically made the report
to the police in order to cause the Plaintiff and his family great
distress.
(22) On various occasions agents an/or employees of the First Defendant, as
part of its campaign against the Plaintiff, have publicly made false
and damaging allegations concerning the Plaintiff. The Plaintiff relies
on the following:
(a) In or about February 1993, the Church of Scientology published
and/or authorised the publication of a pamphlet entitled "A
short Appraisal of Parts of the Novel: 'A Piece of Blue Sky'."
The pamphlet contained a critique of the Plaintiff's book and also
untruthful assertions concerning the Plaintiff personally,
including the allegation that the Plaintiff had written the book
dishonestly and in bad faith. The Plaintiff will rely on the whole
of the said pamphlet as evidence of malice.
(b) In July 1993, the Plaintiff's wife Noella was declared a
"Suppressive Person" for publicly leaving the Church and
associating with the Plaintiff. Noella Caven-Atack was sent a
written declaration dated 14th July 1993 which contained the
follwoing words referring to her and to the Plaintiff:
"Noella assisted in the writing of Jon Atack's anti-Scientology
book, which was a complete failure. This book was intended to spread
malicious lies about the Church and its parishioners, in an attempt
to mislead and confuse those people seeking better lives".
The Plaintiff will rely on the entire contents of the said declaration
and on the covering letter received with it.
(c) In or about March 1994, the Church of Scientology circulated a
leaflet entitled, "Deprogramming Victims Network Newsletter
--United kingdom Update" to homes in and around East Grinstead.
The leaflet contained various spiteful and false allegations against
the character of the Plaintiff, including allegations that:
(i) was a drug dealer;
(ii) was an avid reader of black magic;
(iii) conducted a hate campaign against the Church of Scientology;
(iv) had taken part in an international criminal conspiracy to
kidnap Scientologists.
The Plaintiff will rely on the whole of the Newsletter for its true
terms and effect.
(d) Further to the letter containing the words set out in Paragraph 7
herein, on or about 5 April 1994 solicitors for the Church of
Scientology, Messrs. Hodkin & Company, wrote on behalf of the
organisation a letter to Mr. Andrew Neill, the Editor of The Sunday
Times, repeating various personal attacks on the character of the
Plaintiff, including the allegation that the Plaintiff's aim in his
work was to extort a large sum of money from the Church of
Scientology. The Defendant will rely on the whole of the said
letter.
(e) On or about 13 March 1994 33 members of the Church of Scientology
wrote a letter headed, "OPEN LETTER RE: YOUR ANTI-SCIENTOLOGY
ACTIVITIES" to the Plaintiff containing false and offensive
allegations concerning the Plaintiff. It is to be inferred from
the heading of the letter that it was sent to persons other than the
Plaintiff. The Plaintiff will rely on the whole of the said letter,
and in particular the allegations contained therein that he had made
threats to destroy tshe Chruch of Scientology which were "the
deluded ravings of a madman"; that he sought to profit by
spreading lies; that he was evil and an utter fraud.
(f) The Plaintiff will further rely on an article published in the issue
for March 1994 of CAN Reform Group - Membership news under the
heading "British CAN Associate Thrown Out of Court"
containing false and misleading allegations of the Plaintiff; and on
an article published in or about March 1994 under the heading
"Factnet--Perversions, Criminality and Lies" containing
further false and damaging accusations about the Plaintiff.
(23) The Plaintiff relies on the tone as well as the contents of the
publications complained of and those referred to in Particulars (2)
and (23) above to show the relentless hostility of the Defendants
to the Plaintiff personally, their desire to caouse him distress and
hurt the Plaintiff, and their reckless disregard for fairness and
the truth. The tone of the Church of Scientology's attacks on the
Plaintiff's character was spiteful, vindictive and abusive.
(24) The First to Fourth Defendants had no evidence that the allegation
complained of were true, but nonetheless recklessly published them
not caring whether they were true or false, with the motive of
furthering their campaign against the Plaintiff and of destroying
or seriously damaging the Plaintiff's personal and professional
reputation and hindering his ability from making a living from his
expertise on Scientology.

The words set out in Paragraph 4 herein were calculated to cause
pecuniary damage to the Plaintiff.

In aggravation of damages, the Plaintiff will rely on the fact that the
publication of the words complained of has caused the Plaintiff great
personal distress and public humiliation.

Unless restrained by this Honourable Court, the Defendants will publish
the same or similar false words about the Plaintiff.

Further or altrnatively, on 13, 15, 16, and 17 March and 6 and 10 April
1994 the Fifth and Sixth Defendants and other agents and/or employees of the
Church whom the Plaintiff cannot identify, on behalf of themselves and the
First Defendant, and/or authorised by the First Defendant, staged
demonstrations outside the Plaintiff's house.

PARTICULARS
(1) Particulars (15) to (20) under the Particulars of
Malice under Paragraph 9 above are repeated.

As a result of matters aforesaid the Plaintiff and his family have been
caused and are caused distress, embarrassment, nuisance and annoyance and
have been put in fear of their personal safety and the Plaintiff has thereby
suffered damage.

Unless restrained by this Honourable Court, the First, Fifth and Sixth
Defendants intend and threaten to further watch and beset and demonstrate
outside the Plaintiff's property, harrass, cause nuisance annoyance and
distress to the Plaintiff and his family.

Further, pursuant to section 69 of the County Courts Act 1984 the
Plaintiff claims interest on the amount found due at such rate and for such
period as the Court thinks fit.

AND the Plaintiff claims:-

(1) Against the First to Fourth and Seventh Defendants, damages including
aggravated damages, for malicious falsehood.
(2) Against the First to Fourth and Seventh Defendants an injunction
restraining the said Defendants and each of them whether by themselves their
servants agents or otherwise from further publishing the same or any similar
false words about the Plaintiff.
(3) Against the First, Fifth and Sixth Defandants, damages for nuisance; and
interest as aforesaid thereon.
(4)Against the First, Fifth and Sixth Defendants, an injunction restraining
the said Defendants whether by themselves their servants agents or otherwise
from further continuing the said nuisance by:
(a) besetting the Plaintiff's property; or
(b) harrassing the Plaintiff and/or his family; or by any other
means.
ALEXANDRA MARZEC
BEVERLEY L. RYALL
93 Westgate
Chichester PO19 3HB
Solicitor for the Plaintiff